CMS has finalized a new “efficiency” adjustment to non–time-based physician work codes in the Medicare Physician Fee Schedule. This policy reduces work RVUs based on the assumption that physicians can safely complete complex services in less time. Several time-based services, including E/M, are exempt, but electrophysiology services are not. Unless Congress acts, these changes will take effect on January 1.

HRS/HRA Advocacy to Date
HRS and HRA strongly opposed implementation of the -2.5% efficiency adjustment in our comment letter to CMS on the Medicare Physician Fee Schedule proposed rule. We emphasized that this policy is not supported by adequate evidence and does not reflect the realities of complex procedural care. Despite widespread concern across specialties, CMS finalized the policy.

Why This Matters for EP:
Electrophysiology procedures and device management are long, complex, and high-risk, particularly for older adults with serious arrhythmias. These services require careful planning, individualized decision-making, and are time-intensive procedures. A policy that assumes they can simply be “done faster” risks:

• Undermining patient safety
• Reducing stability for EP labs and device clinics
• Threatening access to high-complexity care across hospitals, practices, and rural settings
• Relying on assumptions that do not reflect real-world EP practice

What Congress Can Do:
Congress is considering legislation that would:

• Delay these cuts beyond January 1
• Require a one-time, evidence-based study to determine whether the “efficiency” assumptions are valid and safe

• Use existing money in the Medicare Improvement Fund to pay for the delay

Our contacts in Senate offices have indicated that this is the most viable path forward, and they need to hear from clinicians and advocates now.

Please send a message to your Senators and Representative today. Your perspective - especially how these changes affect your patients - can make a significant difference.